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In the case of Sant Ram v Rajinderlal, the Supreme Court said that welfare legislation must
be interpreted in a third World perspective favouring the weaker and poor class. It has also
been laid down in the case of labour legislation that courts should not stick to grammatical
constructions but also have regard to ‘teleological purpose and protective intendment of
the legislation. Interpretation of labour legislations should be done by the courts with more
concern with the colour, the context and the content of the statute rather than its literal
import.
Industrial Disputes Act 1947 is one of welfare statute which intends to bring about peace
and harmony between management and labour in an industry and improve the service
conditions of industrial workers which in will turn accelerate productive activity of the
country resulting in its prosperity. As a result, the prosperity of the country in turn will help
to improve the conditions of the workmen. Therefore, this statute should be interpreted in
such a way that it advances the object and the purpose of the legislation and gives it a full
meaning and effect so that the ultimate social objective is achieved. The courts while
interpreting labour laws have always stressed on the doctrine of social justice as enshrined
in the Preamble of Constitution.
Beneficial Construction – A tendency rather than a rule
It is said by Maxwell, that Beneficial Construction is a tendency and not a rule. The reason is
that this principle is based on human tendency to be fair, accommodating, and just. Instead
of restricting the people from getting the benefit of the statute, Court tends to include as
many classes as it can while remaining faithful to the wordings of the statute. For example,
in the case of Alembic Chemical Works v Workman, an industrial tribunal awarded a greater
number of paid leaves to the workers than what Section 79(1) of Factories Act
recommended. This was challenged by the appellant. SC held that the enactment being
welfare legislation for the workers, it had to be beneficially constructed in the favour of
worker and thus, if the words are capable of two meanings, the one that gives benefit to the
workers must be used.
When a statute is meant for the benefit of a specific class, and if a word in the statute is
capable of two meanings, one which would preserve the benefits and one which would not,
then the meaning that would preserve the benefits must be adopted and shall be followed
by the court of law. It is important to note that omissions will not be supplied by the court.
Only when multiple meanings are possible, can the court shall pick the beneficial one. Thus,
where the court has to choose between a wider mean that carries out the objective of the
legislature better and a narrow meaning, then it usually chooses the former meaning
carrying out the objective of the legislation. Similarly, when the language used by the
legislature fails to achieve the objective of a statute, an extended meaning could be given to
it to achieve that objective, if the language is fairly susceptible to the extended meaning.
Limitation On the Application of Beneficial Construction
If on the application of the rule of beneficial construction, the court finds that it is doing
complete justice and delivering a fair judgment then there is no question of why should not
such rule is applied? But there are certain restrictions which the court has to take care of
which at the time of application have to be adhered to –
1. Where the courts find that by the application of the rule of beneficial construction, it
would be re legislating a provision of statute either by substituting, adding or altering any
provision of the act.
2. Where any word in a statute confers to a single meaning only. Then the courts should
refrain from applying the rule of benevolent construction to the statute.
Conclusion
The conclusion shall be the final analysis of the comparison between the rule of Harmonious
Construction and rule of Beneficial Construction. Harmonious construction is only applied
where there is a conflict between the meaning coming out of two different sections and the
meaning land the courts in dubious situation of which section to apply? Whereas, the rule of
Beneficial Construction is applied in the cases where any construction may do any benefit to
the society or any group of people and are basically applied in the socio – economic
legislations. Here there is no conflict between the meanings of any two sections and
meanings attributed to them.
Therefore the rule of Harmonious Construction and Beneficial Construction both play an
important in the interpretation of statutes and are two important rules of interpretation.